ML18313A083

NRR E-mail Capture - Request for Additional Information Prairie Island NFPA-805 License Condition Modification Amendment Request

ML18313A083
Person / Time
Site:	Prairie Island
Issue date:	11/07/2018
From:	Robert Kuntz Plant Licensing Branch III
To:	Gohdes P Northern States Power Co
References
L-2018-LLA-0147
Download: ML18313A083 (3)

Text

NRR-DMPSPEm Resource From: Kuntz, Robert Sent: Wednesday, November 7, 2018 2:37 PM To: 'Gohdes, Peter D.'

Subject:

Request for Additional Information RE: Prairie Island NFPA-805 License Condition Modification Amendment Request Mr. Gohdes, By letter dated May 18, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18138A402), as supplemented by letter dated July 10, 2018 (ADAMS Accession No. ML18191A265),

Northern States Power Company, a Minnesota corporation (NSPM, the licensee), doing business as Xcel Energy, submitted a license amendment request (LAR) to revise its license condition associated with implementation of its risk-informed, performance-based fire protection program at the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the submittals and determined that additional information is required to complete its technical review. The request for additional information (RAI) is provided below. During a clarification call on November 7, 2018 a date of December 7, 2018 was determined for NSPM to provide a response to this RAI.

Robert Kuntz Senior Project Manager NRC/NRR/DORL/LPL3 (301)415-3733 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST (LAR) TO CHANGE LICENSE CONDITION ASSOCIATED WITH IMPLEMENTATION OF THE RISK-INFORMED, PERFORMANCE-BASED FIRE PROTECTION PROGRAM NORTHERN STATES POWER COMPANY - MINNESOTA (NSPM, THE LICENSEE)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT (PINGP), UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 (EPID L-2018-LLA-0147)

PRA RAI 01 National Fire Protection Association Standard 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), (NFPA 805), as referenced in paragraph 50.48(c) of Title 10 of the Code of Federal Regulations (10 CFR), Section 4.2.4.2, requires that the use of fire risk evaluation for the performance based approach shall consist of an integrated assessment of the acceptability of risk, defense in depth (DID), and safety margins. Element 3 of DID is met by providing an adequate level of 1

fire protection for structures, systems and components important to safety, so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.

The LAR dated May 18, 2018, proposed to not complete modification 20 and included discussions on risk, DID, and safety margins. In the DID discussion for DID element 3, the licensee stated that an adequate level of fire protection is maintained because the impact of the lack of electrical coordination is included in the FPRA model and the results remain acceptable. Based on this information, the NRC staff is unable to determine if the proposed change meets DID element 3.

Provide information that fully explains how DID element 3 is met for this proposed change, including justification that an adequate level of fire protection is maintained for structures, systems and components important to safety, so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.

2

Hearing Identifier: NRR_DMPS Email Number: 658 Mail Envelope Properties (BN6PR09MB15070ECC5F1CE37DC30CA8DA99C40)

Subject:

Request for Additional Information RE: Prairie Island NFPA-805 License Condition Modification Amendment Request Sent Date: 11/7/2018 2:37:11 PM Received Date: 11/7/2018 2:37:12 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients:

"'Gohdes, Peter D.'" <Peter.Gohdes@xenuclear.com>

Tracking Status: None Post Office: BN6PR09MB1507.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3086 11/7/2018 2:37:12 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: